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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Luxembourg: Source of income

For the purposes of the Elimination of double taxation Article, income which may be taxed in Luxembourg under the agreement is deemed to be income from sources in Luxembourg (Article 25(1)). Interest and royalties are deemed to arise in the country of which the payer is a resident (Articles 11(6) and 12(5)).